October 19, 2010
BEFORE THE
OFFICE OF ENERGY EFFICIENCY AND RENEWABLE ENERGY
UNITED STATES DEPARTMENT OF ENERGY
WASHINGTON, DC
Statement of Policy for Adopting Full-Fuel-Cycle Analyses Into Energy Conservation Standards Program
EERE-2010-BT-NOA-0028
RIN 1904-AC24
COMMENTS OF THE AMERICAN GAS ASSOCATION
Introduction
Pursuant to the Notice of Proposed Policy (“Notice”) issued August 20, 2010,1 the American Gas Association (“AGA”) is pleased to submit comments in response to the proposed policy of the U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy (“Department” or “DOE”) to adopt full-fuel-cycle analyses into its energy conservation standards program. AGA supports the proposal and encourages the Department to take additional steps to implement the recommendations of the National Academy of Sciences regarding the use of full-fuel cycle measures into the establishment of energy conservation standards.